Episode 89: EU and UK TP controversy trends and outlook

TP Talks - PwC's Global Transfer Pricing podcast

In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more.

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1. Episode 89: EU and UK TP controversy trends and outlook (00:00:00)

2. What are tax authorities focusing on in the EU and UK with respect to TP audits and what can taxpayers expect going forward? (00:01:42)

3. Is DAC 6 reporting and country-by-country reporting generating audit activity? (00:15:53)

4. What transfer pricing litigation trends do you see? (00:19:18)

5. Will the bilateral APA manual issued by OECD Forum on Tax Administration have a short term impact? How does the current global policy environment impact dispute resolution? (00:22:34)

6. What discussions are you having with clients regarding BEPS 2.0; specifically Pillars One and Two? (00:30:56)

7. What are your key takeaways for listeners? (00:34:20)